Ernest Hemingway replied to F. Scott Fitzgerald's observation that the rich "are different from you and me" with the comment, "Yes, they have more money."

Now comes Johnston, a Pulitzer Prize-winning journalist, with a thorough examination of another way in which the rich differ from low-income, middle-income and merely affluent people. Johnston shows in his new book, Perfectly Legal, that Americans who have the most money pay less of it in taxes than other Americans.

"The tax system is being used by the rich, through their allies in Congress, to shift risks off themselves and onto everyone else," Johnston writes. "And perhaps worst of all, our tax system now forces most Americans to subsidize the lifestyles of the very rich, who enjoy the benefits of our democracy without paying their fair share of its price."

Although Johnston agrees that the rich pay most of the income taxes, he insists that they do not pay a disproportionately large share of the tax burden.

He points out that in 2000, the top 400 taxpayers had an average income of $174 million and paid 22 cents on the dollar in federal income taxes, roughly equivalent to what a single taxpayer who earned in the low six figures made.

"Had the 2003 tax cuts been in effect, the top 400 would have paid just 17.5 cents on the dollar, not much more than the overall national average of 15.3 cents that Americans actually paid that year," Johnston writes.

Those figures, however, are based on reported income. Much of Perfectly Legal homes in on the strategies used by the super rich to hide their wealth, transfer it abroad and insulate it in tax shelters.

Johnston maintains that the IRS' concentration on trying to find inflated deductions on tax returns is a "trivial pursuit" when immense amounts of untaxed money are circulating unnoticed.

The author describes how tax cuts supposedly intended to help the middle class benefit the super rich far more, how companies locate headquarters in other countries to avoid taxes, how patents are registered abroad to avoid taxes on their revenue stream, how executives build megabucks retirement nest eggs while employees' retirement funds dry up, how super-rich executives defer their compensation to avoid taxes and how the rich often use life insurance for tax avoidance.

He points out that repeal of the estate tax, one of President Bush's favorite causes, is being sold as tax relief for the middle class when primarily the very rich would benefit from it.

Johnston prescribes numerous remedies for what he sees as the inequitable tax system robbing the nation of resources needed to provide adequate services and opportunities for citizens and robbing the majority of Americans of the ability to save while the rich line their pockets.

Among those recommendations is a call for Congress to end the requirement that corporations keep two sets of books, one for shareholders and the other for the IRS.

Perfectly Legal is well timed, coming as it does in an election year.

Johnston has clarified the real issues of taxation so well that journalists and others who read it will have many questions on the subject in their quivers to let fly at candidates.